In
State v. Lyle, 854 N.W.2d 378, 400 (Iowa 2014), the
Iowa Supreme Court held that mandatory-minimum sentences
automatically imposed on defendants for crimes committed as
juveniles are "unconstitutional under the cruel and
unusual punishment clause in article I, section 17 of [the
Iowa] constitution." In this postconviction-relief
action, Corey Crawley seeks to expand that holding to his
circumstances, arguing that although he was legally an adult
when he committed second-degree robbery, he was not mentally
an adult because of his lower-than-average intelligence and
his young age of eighteen-and-eight months.[1] On that basis, he
contends the mandatory-minimum aspect of his sentence is
cruel and unusual as applied to him under the Eighth
Amendment of the Federal Constitution and article 1, section
17 of the Iowa Constitution. Upon our de novo review, see
State v. Oliver, 812 N.W.2d 636, 639 (Iowa 2012), we
affirm.

Both
the U.S. Constitution and the Iowa Constitution prohibit the
infliction of cruel and unusual punishment. See U.S.
Const. amend. VIII; Iowa Const. art. I, § 17
("Excessive bail shall not be required; excessive fines
shall not be imposed, and cruel and unusual punishment shall
not be inflicted."). Underlying the constitutions'
prohibition is the venerable adage "that punishment
should fit the crime." State v. Bruegger, 773
N.W.2d 862, 872 (Iowa 2009). "[T]he right to be free
from cruel and unusual punishment flows from the basic
'precept of justice that punishment for crime should be
graduated and proportioned to offense.'" State
v. Null, 836 N.W.2d 41, 57 (Iowa 2013) (citation
omitted). However, the right's meaning and interpretation
is "not static" but rather ever evolving. See
Lyle, 854 N.W.2d at 384. Thus, constitutional challenges
alleging cruel and unusual punishment must be considered
under the current, prevailing "standards of whether a
punishment is 'excessive' or 'cruel and unusual,
'" drawing "meaning from the evolving standards
of decency that mark the progress of a maturing
society." Id. Based on these principles, the
Supreme Court over time has identified certain categorical
circumstances wherein the imposition of austere punishments
is considered cruel and unusual, irrespective of
idiosyncratic facts. See Miller v. Alabama, 132
S.Ct. 2455, 2460 (2012) (holding "mandatory life without
parole for those under the age of [eighteen] at the time of
their crimes violates the Eighth Amendment's prohibition
on "cruel and unusual punishments"); Graham v.
Florida, 560 U.S. 48, 82 (2010) (holding "the
imposition of a life without parole sentence on a juvenile
offender who did not commit homicide" is cruel and
unusual punishment); Kennedy v. Louisiana, 554 U.S.
407, 413, 438 (2008) (holding an offender cannot be sentenced
to death- regardless of their personal characteristics-where
the offender was only convicted of a nonhomicide offense and
"the crime did not result, and was not intended to
result, in [the] death of the victim"); Roper v.
Simmons, 543 U.S. 551, 578 (2005) (holding the death
penalty cannot be imposed, irrespective of the crime, on a
juvenile offender); Atkins v. Virginia, 536 U.S.
304, 321 (2002) (holding that death penalty cannot be
imposed, irrespective of the crime, on an intellectually
disabled criminal offender).

In
Roper, the Court categorically barred
"imposition of the death penalty on any offender under
[eighteen] years of age, " explaining:

The differences between juvenile and adult offenders are too
marked and well understood to risk allowing a youthful person
to receive the death penalty despite insufficient
culpability. An unacceptable likelihood exists that the
brutality or cold-blooded nature of any particular crime
would overpower mitigating arguments based on youth as a
matter of course, even where the juvenile offender's
objective immaturity, vulnerability, and lack of true
depravity should require a sentence less severe than death.
In some cases a defendant's youth may even be counted
against him.

543 U.S. at 572-73. The Court recognized that the
"qualities that distinguish juveniles from adults do not
disappear when an individual turns eighteen" and,
"[b]y the same token, some under [eighteen] have already
attained a level of maturity some adults will never
reach." Id. at 574. Nevertheless, it accepted
that "a line must be drawn" somewhere between
childhood and adulthood, and, because eighteen "is the
point where society draws the line for many purposes, "
it was "the age at which the line for death eligibility
ought to rest." Id.; see also United States
v. Marshall, 736 F.3d 492, 498 (6th Cir. 2013)
("The Supreme Court has recognized that drawing lines
based on chronological age is a not-entirely-desirable but
nonetheless necessary approach.").

Like
Roper, the Iowa Supreme Court limited its holding in
Lyle to only those "cases involving conduct
committed by youthful offenders, " stating that although
"categorical rules can be imperfect, . . . one is
necessary here." Lyle, 854 N.W.2d at 402. The
court explicitly stated its holding

ha[d] no application to sentencing laws affecting adult
offenders. Lines are drawn in our law by necessity and are
incorporated into the jurisprudence we have developed to
usher the Iowa Constitution through time. This case does not
move any of the lines that currently exist in the sentencing
of adult offenders.

Id. at 403. If the supreme court&#39;s
pronouncements are to be changed, they are best addressed by
that court, as we are bound by its holdings. See State v.
Miller, 841 N.W.2d 583, 584 n.1 (Iowa 2014)
("Generally, it is the role of the supreme court to
decide if case precedent should no longer be
followed."); State v. Hughes, 457 N.W.2d 25, 28
(Iowa Ct. App. 1990) (citing State v. Eichler, 83
N.W.2d 576, 578 (1957) ("If our previous ...

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